OFFICE: Toronto CONTACT: (416) Featured Articles and Seminars

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1 Michael Colborne OFFICE: Toronto CONTACT: (416) Featured Articles and Seminars "Subsection 247(3): What Are "Reasonable Efforts?", International Tax Planning feature (2016) 64:1 Canadian Tax Journal , with Michael McLaren and Mark Barbour. Canada, in International Comparative Legal Guide to Corporate Tax 2016 (London: Global Legal Group, 2015), with Michael McLaren. An Opportunity to Clarify the Scope of the Large Corporation Objection Rules: Devon Canada Corporation v. The Queen, Current Cases feature (2015) 63:1 Canadian Tax Journal , with Tim Barrett. Tax Court Doesn t Hedge in Rebuffing CRA's Hedging Position: George Weston Limited v. The Queen, Current Cases feature (2015) 63:2 Canadian Tax Journal , with Tim Barrett. Transfer Pricing - The Reasonable Efforts Standard Under Subsection 247(3) of the Income Tax Act: Where Are We? (2015) 20:4 International Tax Planning 7-9, with Tim Barrett. "2013 Mining Update," in Report of the Proceedings of the Sixty-Fifth Tax Conference, 2013 Conference Report (Toronto: Canadian Tax Foundation, 2014), 9:1-19, with Lana Paton. Canada, in World Tax 2015: The Comprehensive Guide to the World s Leading Tax Firms (London: Euromoney Institutional Investor PLC, 2014), with Michael McLaren and Tim Barrett.

2 Page 2 of 5 Canada, in International Comparative Legal Guide to Corporate Tax 2014 (London: Global Legal Group, 2013), with Michael McLaren. Canada, in World Tax 2014: The Comprehensive Guide to the World s Leading Tax Firms (London: Euromoney Institutional Investor PLC, 2013), with Michael McLaren and Mark Barbour. Regulation 5907(2.03) and Offshore Metal Streams (2013) 9:2 Resource Sector Taxation Tax Structuring for Canadian Investment in Latin American Mining Projects, in Special Institute on International Mining and Oil & Gas Law, Development and Investment (Westminster, CO: Rocky Mountain Mineral Law Foundation, 2013), 2013:2, with Steve Suarez. Canada, in International Comparative Legal Guide to Corporate Tax 2013 (London: Global Legal Group, 2012), with Michael McLaren. Canada, in World Tax 2013: The Comprehensive Guide to the World s Leading Tax Firms (London: Euromoney Trading Limited, 2012), with Michael McLaren and Mark Barbour. Mexican Service Companies Reform of Federal Labor Law in Mexico May Affect Companies with Mexican Operations (2012) 18:2 International Tax Planning 7, with Mark Barbour. Shareholder Benefit Rules More Collateral Damage: Proposed Changes to Shareholder Benefit Rules and Foreign Divisive Reorganizations (2012) 17:4 International Tax Planning 8-9, with Mark Barbour. Strategic Considerations in a Typical TSX Mining Takeover - A Case Study, in 58 th Annual Rocky Mountain Mineral Law Institute (Westminster, CO: Rocky Mountain Mineral Law Foundation, 2012), with Jeffrey P. Roy. Timber! Consequences of Assuming Reforestation Obligations: Diashowa Paper Manufacturing Ltd. v. Canada, Current Cases feature (2012) 60:1 Canadian Tax Journal , with Steve Suarez.

3 Page 3 of 5 "2010 Mining Update," in Report of Proceedings of Sixty-Second Tax Conference, 2010 Conference Report (Toronto: Canadian Tax Foundation, 2011), 13:1-49, with Mark Ruus. Canada, in International Comparative Legal Guide to Corporate Tax 2012 (London: Global Legal Group, 2011), with Michael McLaren. Canada, in World Tax 2012: The Comprehensive Guide to the World s Leading Tax Firms (London: Euromoney Trading Limited, 2011), with Michael McLaren and Mark Barbour. Payments Made in Takeover Not Deductible, Tax Court Says (2011) 61:2 Tax Notes International 270, with Michael McLaren. Rezayat, Yang, Hamley and Capancini: Inconsistent Tax Court Decisions (2011) 16:4 International Tax Planning , with Mark Barbour. Canada, in World Tax 2011: The Comprehensive Guide to the World s Leading Tax Firms (London: Euromoney Trading Limited, 2010), with Michael McLaren. Foreign Taxes Chile Introduces New Mining Royalty Regime (2010) 16:1 International Tax Planning 8, with Alberta Maturana. Legislative Update The 2010 Federal Budget Resource Industry (2010) 7:3 Resource Sector Taxation 7-8. "Section 93 Elections - Proposed Amendments," International Tax Planning feature (2010) 58:2 Canadian Tax Journal , with Michael McLaren. Tax Policy 2010 IGWG Report a Tepid Response (2010) 8:2 Resource Sector Taxation "The Limitation-on-Benefits Article in the Fifth Protocol to the Canada-US Tax Convention," in Report of Proceedings of Sixtieth Tax Conference, 2008 Conference Report (Toronto: Canadian Tax Foundation, 2009), 25:1-58, with Shawn D. Porter. Tax Reform (Mexico) Considerations in Relation to the 2010 Mexican Tax Reform (2009) 15:2 International Tax Planning 9-11, with Alejandro Barrera Basham, Ringey Correa and Michael McLaren.

4 Page 4 of 5 Transfer Pricing: GlaxoSmithKline Inc. v. The Queen, Current Cases feature (2008) 56:4 Canadian Tax Journal , with Michael McLaren. "Section 93 Elections," International Tax Planning feature (2007) 55:4 Canadian Tax Journal , with Michael McLaren. Provincial Mining Taxes Reorganization and the Mining Tax Act (Ontario) (2006) 4:4A Resource Sector Taxation What You Should Know About Mining and Taxation (2006) 17:6 International Tax Review 48-50, with Terry Barnett. Article XXIX(5) and the Draft Competent Authority Circular (2003) 11:4 International Tax Planning Capital Cost Allowance Class 10(g) and the Ownership of Mineral Resources (2003) 2:1 Resource Sector Taxation CCRA Update Paragraph 20(1)(e) of the Income Tax Act: The Wholly-applicable Test (2003) 11:2 Corporate Finance "Any Form of Guarantee..." (2002) 10:5 Canadian Tax Highlights Contingency Fees Contingency Fees Revisited: Guidelines to Determine if an Agreement is Champertous (2001) 9:4 Tax Litigation 5-7, with Matthew G. Williams. "The Fairness Provisions: Judicial Review" (2001) 1:4 Tax for the Owner-Manager 21. "More Questions Than Answers" (2001) 9:4 Canadian Tax Highlights Foreign Property Foreign Property Rules and Transfer of Assets (1998) 9:8 Taxation of Executive Compensation and Retirement 13-15, with William R. Holmes. Will a Gentleman Farmer Who Suffers Farm Losses Ever Be Successful Before the Federal Court of Appeal: The Queen v. Donnelly, Current Cases feature (1998) 46:1 Canadian Tax Journal 87-90, with L.M. Little.

5 Page 5 of Federal Budget Changes Relating to RRSPs (1997) 4 RRSP Planning 262, with William R. Holmes.